Regulation guide

RBI Digital Lending

Operationalize the RBI Digital Lending requirements—from regulatory obligations and evidence collection to vendor assessments, continuous monitoring, governance, and remediation workflows.

Overview

RBI digital lending guidance governs how regulated entities use digital lending apps and lending service providers.

RBI wants borrowers to understand who is lending, what costs apply, where money flows, how data is used, and how complaints are handled. Regulated entities remain accountable for lending service providers and digital lending apps used in the lending lifecycle.

Rather than prescribing identical controls for every relationship, the regulation emphasizes a risk-based approach, requiring organizations to apply governance, oversight, controls, monitoring, and due diligence according to the criticality and risk of each relationship.

This implementation guide explains what the regulation requires, how those requirements translate into operational controls and evidence, and how Halbarad helps organizations operationalize compliance through assessments, continuous monitoring, governance workflows, and supply chain risk intelligence.

Official Sources

Intent of the Guide

RBI wants borrowers to understand who is lending, what costs apply, where money flows, how data is used, and how complaints are handled. Regulated entities remain accountable for lending service providers and digital lending apps used in the lending lifecycle.

Operationalization Requirements

  • Map regulated entities, lending service providers, digital lending apps, technology providers, and

customer touchpoints.

  • Review disclosures, key fact statements, fund-flow arrangements, fees, data collection, consent,

storage, and grievance redressal.

  • Monitor LSP and DLA behavior, complaints, incidents, data practices, and customer-impact issues.
  • Preserve evidence for outsourcing accountability and RBI review.

Evidence Requirements

  • LSP and DLA inventory.
  • Customer disclosure and key fact statement evidence.
  • Data collection, consent, storage, and privacy records.
  • Fund-flow and fee evidence.
  • Complaint, incident, remediation, and monitoring records.

Common Gaps

  • Digital lending app vendors are tracked as technology vendors but not customer-outcome providers.
  • Data collection by LSPs is not mapped in enough detail.
  • Complaint handling is not connected to provider oversight.

How Halbarad Helps

Halbarad helps connect LSPs, DLAs, customer journeys, data practices, disclosures, complaints, incidents, remediation, and approvals in one record.

Disclaimer

This guide is for general information only and is not legal advice. Review the official regulation, guidance, and supervisory materials, and consult qualified counsel or compliance advisors for your organization's specific obligations.